Label Information 101

Interpreting Pet Food Labels

This article will give you a quick overview about what the
labels on a pet food tell you - and more important what they
don't tell you. It is based on the
FDA consumer information provided by the
Center
for Veterinary Medicine (parts are quoted in the grey
boxes) and has my own comments added below. I have chosen not
to simply link to that page and let it speak for itself, since
it cites overly long examples but leaves out some relevant
information entirely and is also outdated in some respects.

What is the AAFCO?

Before getting into the specifics, I would like to outline
what the often-mentioned Association of
American Feed
Control Officials is. This group regulates the pet food
industry, and while the board consists of state and federal
representatives, it is not a government body and also includes
people directly involved in the industry. According to the
definition on their website, the AAFCO "provides a
mechanism for developing and implementing uniform and
equitable laws, regulations, standards and enforcement
policies for regulating the manufacture, distribution and sale
of animal feeds", but if this process includes business
insiders, they are likely to protect their own interests
first before anything else.

Their decisions are also the reason why pet food manufacturers
(even if they wanted to) still can't use a more honest,
descriptive labeling system, with less opportunity to make a
product look better than it actually is, thus effectively
protecting those companies that sell poor quality food.
Manufacturers who use quality ingredients don't have anything
to hide - they will proudly display e.g. chicken meal, whole
grains and fresh vegetables. Those who are using ingredients
like chicken byproduct meal, brewer's rice and corn gluten
meal would have a hard time justifying the price of their
foods.

Information on the label

Product Name

The product name is the first part of the label
noticed by the consumer, and can be a key factor in
the consumer's decision to buy the product. For that
reason, manufacturers often use fanciful names or
other techniques to emphasize a particular aspect.
Since many consumers purchase a product based on the
presence of a specific ingredient, many product names
incorporate the name of an ingredient to highlight its
inclusion in the product. The percentages of named
ingredients in the total product are dictated by four
AAFCO rules. [...]

If a food is named specifically, e.g. "Beef Dog Food", the
named ingredient must not be less than 95% of the total weight
if the water required for processing is excluded, no less than
70% if the water is included in the calculation. If more than
one ingredient is named, e.g. "Beef and Liver Dog Food", all
of them combined must not be less than 95% (or 70%
respectively) and they must be named in descending order of
content by weight. This description is used almost exclusively
for canned foods.

If a food name includes the word "dinner" (or similar ones
like "formula", "nuggets" etc.), e.g. such as in "Lamb
Formula", the named ingredient must not be less than 25% of
the total weight. If more than one ingredient is named, e.g.
"Lamb and Rice Formula", all of them combined must not be less
than 25% and they must be named in descending order of content
by weight.

Watch out:
Since the named ingredients are only required to
make up 1/4 of the total product, they may not
even be descriptive of the main ingredients! The
manufactur er is not technically lying about what
is used, but if you don't look closely, you may
not be getti ng what you intended to buy.

If the name of a food includes the phrase "with [ingredient]"
(e.g. "with beef"), the named ingredient must not be less than
3% of the total weight.

Watch out:
The mentioned ingredient is only required to m
ake up 3% of the total product, so it will not be
descriptive of the product at all! Unless
you take a close look at the ingredient lists of
such foods, you are very likely to be deceived.

Net Quantity Statement

The net quantity statement tells you how much product
is in the container. There are many FDA regulations
dictating the format, size and placement of the net
quantity statement. None of these do any good if the
consumer does not check the quantity statements,
especially when comparing the cost of products. For
example, a 14-ounce can of food may look identical to
the one-pound can of food right next to it. Also, dry
products may differ greatly in density, especially
some of the "lite" products. Thus, a bag that may
typically hold 40 pounds of food may only hold 35
pounds of a food that is "puffed up." A cost-per-ounce
or per-pound comparison between products is always
prudent.

This bit of information is important when you are comparing
food brands that are sold in differently sized bags. Depending
on the quality of the food, a 33 lb bag of one brand may be
more expensive than a 40 lb bag of another, but the smaller
bag may contain a more concentrated food of which you have to
feed a lot less.

Watch out:
If a particular brand is sold in bags of
different sizes, the smaller the size, the higher
the price per pound.

Example: Brand X comes in bags of 5, 10, 20 and 40
pounds.A 5 lb bag costs $8, the price per pound is
$1.60
A 10 lb bag costs $13, the price per pound is
$1.30
A 20 lb bag costs $21, the price per pound is
$1.05
A 40 lb bag costs $32, the price per pound is
$0.80

As you see, you are paying twice the amount per
pound when you buy the smallest bag. If you are
concerned about freshness and still want to save
money, consider buying a vacuum food sealer to
split the content of one large bag into several
smaller ones. There is no need to refrigerate or
freeze vacuum packed dog food, just store it in a
dark, cool and dry place.

Manufacturer's Name and Address

The "manufactured by..." statement identifies the
party responsible for the quality and safety of the
product and its location. If the label says
"manufactured for..." or "distributed by...," the food
was manufactured by an outside manufacturer, but the
name on the label still designates the responsible
party. Not all labels include a street address along
with the city, State, and zip code, but by law, it
should be listed in either a city directory or a
telephone directory. Many manufacturers also include a
toll-free number on the label for consumer inquiries.
If a consumer has a question or complaint about the
product, he or she should not hesitate to use this
information to contact the responsible party.

This is pretty straightforward and requires no further
explanation.

Ingredient List

All ingredients are required to be listed in order of
predominance by weight. The weights of ingredients are
determined as they are added in the formulation,
including their inherent water content. [...]
Ingredients must be listed by their "common or usual"
name. Most ingredients on pet food labels have a
corresponding definition in the AAFCO Official
Publication. [...]

"Listed in order of predominance by weight" refers to the
weight before processing. This is important to know when you
are comparing products with different moisture content. Even
in dry foods this can be a difference of 4%, or even more if
dry and semi-moist kibble are mixed in the same bag. More
important though, manufacturers can use this rule to make
their product look better than it actually is by using little
tricks like ingredient splitting or use of better quality
ingredients that still retain a lot of water, but the
dehydrated versions of less desirable components.

Watch out:
A good rule of thumb to distinguish the
major components of a food is to look for
the first named source of fat in the
ingredient list. Anything listed before that, and
including it, make up the main portion of the
food, other items are present in much smaller
amounts to add flavor, function as preservatives
or because of their dietary benefits (e.g.
probiotics, vitamins and minerals).

This is important to know when looking for
ingredients that may not necessarily be harmful
but should only be present in small amounts in a
quality product (beet pulp, corn gluten meal
etc.).

A "common or usual name" may be very obvious when looking at
such ingredients like "lamb" or "ground corn", but won't be
common or usual for the average consumer, who has never read
the definition of ingredients like "hydrolyzed chicken
protein", "digest of poultry byproducts" or "corn distillers
grains with solubles".At this point I find it important to
mention that the AAFCO does not provide a lot of relevant
information for consumers on its website. Any non-AAFCO
members interested in their publication (which contains the
definitions and specifics for all feed ingredients) have to
pay $50 to obtain a copy. How many people do you know who
would order this publication just for the purpose of choosing
a new food for their companion dog? If it was viewable online,
the situation would be different.

Watch out:
Ingredient lists can be manipulated in various
ways to make a product look more attractive than
it really is. On the other hand, a plain, honest
ingredient list may also make a quality product
look worse than one of lesser quality with
cleverly formulated ingredients, unless you know
what you are looking for.

Even though product A lists lamb as first
ingredient, the meat still includes about 75%
water. Once the moisture is removed to reach the
final percentage of about 10%, the lamb meat will
have shrunk to 1/4 of the original amount, while
relatively dry ingredients like the different rice
components will not change much. Product B lists
rice as first ingredient, but since chicken is
added in already dehydrated meal form, the amount
will not shrink any further. Together with the
fish meal the product may contain an equal amount
of animal protein and rice and is pretty much
guaranteed to contain more meat than product A.

Product C lists chicken as first ingredient
(again, this still includes about 75% water) but
the much less desirable chicken byproducts in
dehydrated meal form - the finished product will
contain much less "real" chicken than byproducts.
Product D has chicken meal as first ingredient,
and the byproducts as second, which will lose 3/4
of their weight by the time the food reaches its
final moisture content. Product D contains a
larger amount of better digestible animal protein.

To recognize whether a food even includes any real
meat, you need to know the ingredient definitions.
Some animal proteins in "meal" form are of high
quality, including for example the whole
carcasses of slaughtered chickens minus feathers,
heads, feet, or entrails; while ones like "beef
& bone meal" are made from any leftovers
after the quality cuts of meat have been
removed for human consumption. Here are two
example ingredient lists of foods that do not
contain a quality meat source whatsoever,
despite the pretty images on the bag:

Guaranteed Analysis

At minimum, a pet food label must state guarantees
for the minimum percentages of crude protein and
crude fat, and the maximum percentages of crude
fiber and moisture. The "crude" term refers to the
specific method of testing the product, not to the
quality of the nutrient itself.

Some manufacturers include guarantees for other
nutrients as well. The maximum percentage of ash
(the mineral component) is often guaranteed,
especially on cat foods. Cat foods commonly bear
guarantees for taurine and magnesium as well. For
dog foods, minimum percentage levels of calcium,
phosphorus, sodium, and linoleic acid are found on
some products. [...]

Since this website is limited to the topic of dry food, I will
leave out most of the material relating to canned and semi
moist foods. If you are interested in those, please refer to
the
FDA document.

The guaranteed analysis is given on an "as is" or "as fed"
basis. In order to compare products with different moisture
content you will have to calculate percentages for both
products at an equal moisture content.

Watch out:
Before comparing products by their weight, cost,
content of protein, fat, and fiber, make sure they
have the same content of moisture. If they differ,
you need convert the values for all products to an
equal percentage.

Example:
3 Products list 22% protein, 12% fat and 4% fiber
"as fed". Product A contains 10% moisture, product
B 12% and product C 14%. Note that the more moisture
the food contains, the less nutritious dry matter is present - meaning you
pay for extra water and get less nutrients:

Product "as fed"

Contains dry matter

Product A

22% protein, 12% fat, 4% fiber, 10% moisture

90%, or 900 g per kg, or 14.4 oz per pound

Product B

22% protein, 12% fat, 4% fiber, 12% moisture

88%, or 880g per kg, or 14.1 oz per pound

Product C

22% protein, 12% fat, 4% fiber, 14% moisture

86%, or 860g per kg, or 13.8 oz per pound

I'll leave it up to you to calculate the
differences in feeding costs per month or year.

Furthermore, it lists the minimum levels of crude
protein and fat and the maximum levels of fiber and water.
"Crude" means the content regardless of quality or
digestibility, leaving you without any means to determine the
true quality of the product from this analysis. A chunk of
meat and a handful of ground up feathers are both sources of
protein, chicken fat and discarded restaurant grease both
provide fat. Which would you rather pay for, but much more
important - which would you rather feed your dog day in and
day out?

Watch out:
Different sources of protein and fat vary in
digestibility and content of valuable nutrients
required to maintain good health. The amount of
food your dog has to eat (and conversely the
amount of cleanup to do, food to buy and money to
spend) strongly depends on the concentration of
nutrients present in a product. Approximate
digestibility values (not the "biological value",
which is a completely different concept) for
protein (based on information published by
T.J. Dunn, Jr. DVM):

Egg whites and whey protein 100%

Muscle meats (chicken slightly higher than
beef or lamb) 92%

Organ meats (heart, kidney, liver) 90%

Fish, whole soybeans (not leftover fragments!)
75%,

Rice 72%

Oats 66%

Yeast 63%

Wheat 60%

Corn 54%

Note: The above does not refer to the total digestibility of the item, but specifically to the percentage to which the protein part can be utilized. Various meat and bone meals and byproduct meals
range from about 45% to 80%, depending on the
content of bone vs. more digestible parts.

The biological value of proteins indicates how
complete a protein source is in regards to content
of the essential amino acids. Combining
ingredients that complement each other results in
an appropriate balance of amino acids. To achieve
this, not all ingredients are required to have
high individual biological values. Example: if the
main protein source of a food is high in
biological value but has a low content of one
particular amino acid, the secondary source only
needs to fill that gap to create the required
balance. I am not able to quote a suitable source
for the BV of different protein sources, since
most tables that are published are relevant for
the essential amino acids for humans (histidine,
isoleucine, leucine, lysine, methionine,
phenylalanine, threonine, tryptophan and valine),
dogs also require arginine in their diet - humans
synthesize it in the liver.

While fats are the main source of energy in a dog
food, they also supply essential fatty acids,
prevent dehydration and serve as carriers for fat
soluble vitamins. Chicken fat, sunflower oil,
various coldwater fish oils and flax oil/seed are
rich in nutrients, while cheaper ingredients like
animal fat, beef tallow, and lard (though very
palatable to dogs, who just love the taste) lack
significant and balanced amounts and are often of
questionable quality.

An interesting side note: Omega 3 and 6 fatty
acids for example are still not recognized
as essential nutrients by the AAFCO dog food
nutrient profile. It is interesting that they are
often referred to by dieticians as
"essential fatty acids" though and
increased supplementation often solves many health
problems. Go figure.

Nutritional Adequacy Statement

[...] A "complete and balanced" pet food must be
substantiated for nutritional adequacy by one of
two means.

The first method is for the pet food to contain
ingredients formulated to provide levels of
nutrients that meet an established profile.
Presently, the AAFCO Dog or Cat Food Nutrient
Profiles are used. Products substantiated by this
method should include the words, "(Name of
product) is formulated to meet the nutritional
levels established by the AAFCO (Dog/Cat) Food
Nutrient Profiles." This means the product
contains the proper amount of protein, calcium,
and other recognized essential nutrients needed to
meet the needs of the healthy animal. The
recommendations of the National Research Council
(NRC) were once used as the basis for nutritional
adequacy, but they are no longer considered valid
for this purpose.

The alternative means of substantiating
nutritional adequacy is for the product to be
tested following the AAFCO Feeding Trial
Protocols. This means that the product, or "lead"
member of a "family" of products, has been fed to
dogs or cats under strict guidelines and found to
provide proper nutrition. These products should
bear the nutritional adequacy statement
"Animal feeding tests using AAFCO procedures
substantiate that (name of product) provides
complete and balanced nutrition." [...]

These two phrases do not really tell you anything about a
product, except that it contains the minimum of nutrients the
AAFCO deems appropriate to keep your dog alive and that he
will survive while eating it. The dictionary defines
the word adequate as "sufficient to satisfy a requirement
or meet a need" - now ask yourself if you want your dog to
survive or to be healthy and thrive? I also find it alarming
that the recommendations of a group of people including
business insiders are favored over those of a
neutral
body of scientists with solid backgrounds in
animal nutrition who do not have a vested interest in
profits from selling food products.

Watch out:
If a product analyzed in an AAFCO laboratory
meets the respective standards established by this
organization, it is considered "complete and
balanced" without actually being tested in feeding
trials. Your dog is not a laboratory and neither
are the nutritional requirements of different
dogs, let alone different breeds, 100% the same.

Just so you can form your own opinion, here are the AAFCO requirements for their feeding trials, passing which is often used as a major point of advertising especially for low quality foods:

Only a minimum of 8 dogs is required as a valid "test group".

There are no restrictions regarding breed or sex.

Of these 8 animals, only 6 are actually required to complete the 26-week trial. The reasons for which an animal might drop out are losing too much weight or other negative side effects.

During the trial, the only food available to the test animals is the food being tested. Water is freely available at all times.

At the beginning and end of the trial the test dogs must pass a physical examination by a veterinarian. The veterinarians evaluate general health, body and hair coat condition.

At the end (but not at the beginning) of the trial, hemoglobin, packed cell volume, serum alkaline phosphatase, and serum albumin are measured and recorded.

The diet being tested fails if any animal shows clinical or pathological signs of nutritional deficiency or excess.

The maximum permissible weight loss during ther trial is 15% of the starting body weight. Specific minimum values for the blood tests are given, and applied to the average result of all participating animals that finished the trial.

There you have it - wouldn't you have expected much more stringent rules, like larger sample groups, a time frame that is longer than just 6 months (for a food your dog might well be eating his or her entire life?), less permissible weight loss for a food that is supposed to be a maintenance diet? 15% is a loss of 7.5 pounds in a 50 lb dog, and unless more than 25% of the test subjects drop out from malnutrition, in the eyes of the AAFCO there is no problem with the product. Feeding trials are also not conducted under conditions that even remotely emulate the environment of a family pet, as they are mostly conducted in kennels of research facilities. A dog who sits in a kennel run all day surely has different nutritional requirements than one who is included in much of it's owners activities and gets a moderate to high amount of exercise every day.

Furthermore, if one particular food in a product line proved to meet the AAFCO standard, the company is allowed to include the nutritional adequacy statement on other products of the same line that provide equal or greater concentrations of all the nutrients. Breed specific health concerns, like for example orthopedic problems in large breeds, hypoglycemia in toy breeds, copper sensivity in Bedlington Terriers, zinc deficiencies in Alaskan Malamutes and other genetic and metabolic differences are not taken into consideration by AAFCO.

Feeding Directions

Feeding directions instruct the consumer on how much
product should be offered to the animal. At minimum,
they should include verbiage such as "feed ___ cups
per ___ pounds of body weight daily. [...]"

This piece of information is a valuable tool for a quick
general comparison of different foods, but the content of
fiber and ash should not be overlooked. Kibble size and
density also vary a lot between different brands.

Watch out:
Please take these recommendations only as very
basic guidelines. How much you have to feed
depends on whether your goal is weight
maintenance, weight loss or gain; the individual
dog's age, breed, metabolism, and activity; and of
course also environmental conditions.
Manufacturers can over- or understate amounts
depending on whether their goal is to sell more
food or to make their product look more economical
than a competitor's.

Calorie Statement

[...] until recently, calorie statements were not
allowed on pet food labels. New AAFCO regulations
were developed to allow manufacturers to
substantiate calorie content and include a
voluntary statement.

If a calorie statement is made on the label, it
must be expressed on a "kilocalories per kilogram"
basis. Kilocalories are the same as the "Calories"
consumers are used to seeing on food labels. A
"kilogram" is a unit of metric measurement equal
to 2.2 pounds. Manufacturers are also allowed to
express the calories in familiar household units
along with the required statement (for example,
"per cup" or "per can"). Even without this
additional information, however, consumers can
make meaningful comparisons between products and
pick the product best suited for their animals'
needs. As with the guaranteed analysis, the
calorie statement is made on an "as fed" basis, so
corrections for moisture content must be made as
described above. [...]

The caloric content of a food gives a good idea about the
digestibility of a product, but it should always be taken into
consideration along with the guaranteed analysis. Fat provides more than twice the amount of energy per weight unit than protein or
carbohydrates, so if a food is slightly higher in fat content,
it will automatically provide more energy.

Watch out:
Caloric statements can be found in three
different values:

Gross Energy - The amount of energy in
a food product on an "as fed" basis.

Digestible Energy - The amount of
energy available to the dog after the amount
lost in feces has been substracted, and

Metabolizable Energy - The amount of
energy available to the dog after the amount
lost in feces, urine and gaseous products of
digestion has been substracted. This is the
most common value used.

It is easily possible to compare "apples and
oranges" unless the Metabolizable Energy
(ME) of all compared products is taken into
consideration.

Example 1:
Manufacturer A lists the following product
information:Gross energy 1,950 Kcal/lb, digestible energy
1,700 Kcal/lb and metabolizable energy 1,550
Kcal/lb.
The competitor B only lists the metabolizable
energy content of 1900 Kcal/lb.
Manufacturer B offers the more nutritious food,
but manufacturer A distracts from the lower
relevant value by providing all 3.

Unless you have a dog who loves eating and tends
to overeat, feeding a more concentrated food is
the better economic solution and also cuts down on
the cleaning up you will have to do, since less
waste is excreted.

Example 2:Two products both list 24% protein, 14%
fat, 3% fiber and 10% moisture.
Product A contains 2,700 Kcal/kg metabolizable
energy, product B contains 3,600 Kcal/kg.
Product B is clearly the better quality food with
more digestible ingredients, you need to feed
much less of it per day compared to product A to supply
the same amount of energy.

Another detail you need to know is that the amount of Kcal
per cup isn't really a good basis of comparison, since a cup
is a measurement for volume, not for weight. Depending on size
and density of the kibble, one cup may hold under 3 ounces(~85 grams)
to over 4 ounces (~113 grams) of food. If you can't locate the
amount of Kcal per pound or kilogram on a product bag or manufacturer
website, email or call to find out.

Other Label Claims

Many pet foods are labeled as "premium," and some
now are "super premium" and even "ultra premium."
Other products are touted as "gourmet" items.
Products labeled as premium or gourmet are not
required to contain any different or higher
quality ingredients, nor are they held up to any
higher nutritional standards than are any other
complete and balanced products.

The term "natural" is often used on pet food
labels, although that term does not have an
official definition either. For the most part,
"natural" can be construed as equivalent to a lack
of artificial flavors, artificial colors, or
artificial preservatives in the product. [...]

"Natural" is not the same as "organic." The latter
term refers to the conditions under which the
plants were grown or animals were raised. There
are no official rules governing the labeling of
organic foods (for humans or pets) at this time,
but the United States Department of Agriculture is
developing regulations dictating what types of
pesticides, fertilizers and other substances can
be used in organic farming.

While it is true that many terms used to market a pet food are
not legally defined, the manufacturers of quality brands go
out of their way to supply their customers with additional
information, such as using hormone free animal products,
pesticide free grains, providing the USDA grades of
ingredients, avoiding genetically modified products and so on.
To put the quoted FDA article into date perspective, as of
Oct. 21, 2002, products labeled as organic require
certification by USDA-accredited certifying agents unless the
operation
qualifies for exemption.

Watch out:
Manufacturers are not required to include
substances in the ingredient list that they did
not add to the product themselves. Products they
obtain from their suppliers may still contain
undesirable ingredients such as synthetic
preservatives and/or other additives. A prime
example is fish meal, which, according to US Coast
Guard regulations, must be preserved with
Ethoxyquin if it is not destined for human
consumption.

So while terms like "human grade", "human
quality", "table quality" etc. may not be legally
defined, they still provide some information about
the quality of certain ingredients and the way
they are handled before they end up in the food
product. If words like "hormone free", "organic"
etc. are used, it is not likely that such
ingredients are feed grade or low quality.

Summary

[...] The pet food label contains a wealth of
information, if one knows how to read it. Do not be
swayed by the many marketing gimmicks or eye-catching
claims. If there is a question about the product,
contact the manufacturer or ask an appropriate
regulatory agency.

It is correct that the pet food label contains a wealth of
information, but it can be very misleading to anyone who has not
read up much on the topic - and to be honest, would you unless you have a reason?
Almost every single element of the label information is of ambiguous nature
and seems to favor the interests of the manufacturer over those of the consumer.
Unfortunately, until a more truthful, customer-friendly
labeling system is implemented, the majority of pet owners
will be swayed by marketing gimmicks and eye-catching claims
because watching cute commercials requires less effort than
understanding the information on the label.

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